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Adaptive Management: Overview and Superfund Task Force Pilot Case Studies Kate Garufi, EPA HQ Course Objectives Gain an understanding of adaptive management and its application and benefits at Superfund mining sites; Understand what


  1. Adaptive Management: Overview and Superfund Task Force Pilot Case Studies Kate Garufi, EPA HQ

  2. Course Objectives • Gain an understanding of adaptive management and its application and benefits at Superfund mining sites; • Understand what site or project management tools are available to support adaptive management; and • Progress and lessons learned from the Superfund task force adaptive management pilots 1

  3. SUPERFUND ADAPTIVE MANAGEMENT OVERVIEW 2

  4. So, why the focus? Superfund Task Force • SFTF Goal 1 : Expediting cleanup and remediation • Strategy 2 : Promote the application of Adaptive Management at complex sites and expedite cleanup through the use of early/interim RODs and removal actions • Recommendation 3: Broaden the use of Adaptive Management (AM) at Superfund sites 3

  5. Issues Common to Complex Sites • Lack of consensus on site understanding and priorities • No clear plan for managing uncertainty • Lack of structured and documented decision-making • Linear project management mentality • Contracting and funding challenges to facilitate innovative and dynamic decision making 4

  6. What is Adaptive Management? • EPA’s working definition: Formal and systematic site or project management approach centered on • rigorous site planning and firm understanding of site conditions and uncertainties Rooted in sound use of science and technology • • Decisions implemented consistent with CERCLA, the National Contingency Plan, and EPA policy and guidance • Focus on taking action and learning: Encourages continuous re- evaluation and prioritization of activities to account for new information or changing conditions. 5

  7. What Adaptive Management is NOT • Trial and error • An end in itself • A silver bullet • One size fits all • Make it up as we go 6

  8. Current Adaptive Management Approach • Current applications are largely reactive versus proactive (informal) • Lack structured documentation (no plans) 7

  9. Elements of AM • Define Site/Project Objectives Plan • Model(s) the site being managed • Identify potential actions • Monitor and evaluate outcomes Adjust Do • Incorporate learning into future decisions Evaluate • Stakeholder participation & Learn 8

  10. Potential Advantages of AM at Superfund Sites Facilitate Site Streamline Decision Cost Control Progress Making • Upfront planning and • Potential for earlier • Helps to prioritize documentation to formalize human health and limited resources on and structure to the ecological risk collecting critical process reduction information to facilitate site completion • Build stakeholder • Early source control consensus and capture • Updating remedial • Putting parts of sites priorities approaches, as back into beneficial needed, based on new • Transparent documentation reuse information of management and resource decisions 9

  11. Adaptive Management Pilot Program • Pilot program focuses on bringing Superfund Adaptive Management application from “ concept ” to “ reality ” by developing and/or implementing Adaptive Management Framework • Application at the Site or Project Level • Outcome: Adaptive Management Site or Project Management Plan (AM SMP or AM PMP) 10

  12. Role of the AM SMP/PMP • Provide a formal process to achieve objectives and maintain forward progress, while documenting the decisions made along the way • Benefits • Increase process transparency • Standardize Documentation • Formal periodic review/updates • Formal process for prioritizing actions • Provide method for course adjustments based on evolving Site understanding (risk, technologies, effectiveness, stakeholder input, etc.) • Key Components • Site Principles • Adaptive Decision Making Process 11

  13. Site Principles • Site principles include: • Goals for the site or project; • Considers how these goals may be prioritized; • Identifies objectives or key adaptive management decision points for the site or project; and • Develops a preliminary site or project-level strategy and schedule • Guides adaptive decision making • Updated on a frequency determined on a site or project level 12

  14. AM SMP: Lessons Learned on Developing Site Principles for a large, complex mining site BONITA PEAK MINING DISTRICT 13

  15. Paradise Mine SITE CHALLENGES 14

  16. Challenge #1: Size and Location • Over 300 historic mines in the BPMD • Silverton: 10,000 – 13,000 feet above sea level • NPL site is 48 source areas across three drainages = >100 square miles 15

  17. 48 NPL Site Source Areas 16

  18. Challenge #2: Source Area Complexities Draining adit Typical Mine drains into waste rock abandoned mine area at Cultural resources? BPMD Seeps Waste rock at creek bank Exposure pathway? 17

  19. Underground Mine Workings Underground Mine Working Complexities 18

  20. Challenge #3: High Social/Political/Legal Profile • Gold King Mine release - 2015 • Interim Water Treatment System performance challenges • Defensive Litigation challenges 19

  21. Challenge #4: Numerous Stakeholders and Agencies • State government interest • Federal partner interest • Tribal nation interest • Local population interest Water quality in the Animas River is key to all groups 20

  22. BPMD: SITE PRINCIPLES DEVELOPMENT 21

  23. BPMD Site Principles Development • Establish EPA Goals: Status – Complete • • Establish WQ Priority Status – Complete • Reaches: • Develop a Site Strategy Status – Ongoing 22

  24. EPA Initial Goals – Established In 2019 CERCLA Goal: Minimize Human Health and Ecological Risks • Goal #1: Improve Water Quality • Goal #2: Stabilize Source Areas • Goal #3: Prevent uncontrolled Releases Note: BLM and USFS have agency-specific goals for work done under their CERCLA authority 23

  25. Result: 4 WQ Priority Reaches • Reach 1: Canyon Reach • Reach 2: Upper Animas at Howardsville • Reach 3: South Fork of Mineral Creek • Reach 4: Upper Mineral Creek 24

  26. Reach 1: Canyon Reach • Objective (Sitewide): Undertake activities necessary to meet Table Value Standards in the Animas River below Elk Creek • Considerations: • Meeting goal requires addressing upstream NPL source areas • Limited data in Canyon Reach 25

  27. Reach 2: Upper Animas at Howardsville • Objective: Improve numbers and spatial extent of the existing brook trout fishery • Considerations: • PRP-lead RI at Mayflower Mill • Significant zinc loaders • Background data needs 26

  28. Reach 3: South Fork of Mineral Creek • Objectives: • Improve numbers and diversity of the existing fishery. • Improve the benthic macroinvertebrate community. • Protect/enhance the trout corridor to Animas River. • Considerations: • Existing trout population • Background data needs • Upgradient sources? 27

  29. Reach 4: Upper Mineral Creek • Objectives: • Investigate the potential for expansion and improvement of the Mineral Creek fishery. • Improve the benthic macroinvertebrate community. • Considerations: • Complicated area • Status of existing fishery? • Background needs 28

  30. Other Reach Considerations: Cement Creek • Objectives: N/A. No focused goals have been established for Cement Creek since viable aquatic life was never present there. • Reducing metal loading in Cement Creek will be critical to the achieving EPA’s water quality goals in Priority Area 1. 29

  31. Site Strategy Development Approach • Focus on high level implementation plan for next 10 years • Develop and explore options Consider pros and cons for each option • • Be inclusive: Solicit stakeholder input on option development (stakeholder involvement in options) • After stakeholder input, make recommendation to management for decision- making • Goals, priorities, and site strategy will be revisited as part of the AM SMP Implementation 30

  32. Adaptive Decision Making • Structured and iterative decision-making process for prioritization of activities based on site principles; • Requirements for developing actions including measurable objectives and monitoring/evaluation of selected actions • Outline the tools and procedures for documenting and communicating decisions • Process for incorporating lessons learned (e.g., results of performance monitoring) 31

  33. AM PMP: Developing an Adaptive Decision Making Approach for the Lower Basin BUNKER HILL: LOWER BASIN 32

  34. 33 Why Adaptive Management? • Provide protection to people from lead- contaminated soils and sediments and • Broad, vague RAOs from contamination in aquatic food • Large area, minimal data sources • Uncertainties • Provide protection to fish, waterfowl, migratory birds, and other plants and • Contaminant source and deposition animals and contribute to a functioning • Remedy effectiveness ecosystem. • Cost • Collateral impacts • O&M • Multiple potential actions • Stakeholders – ‘Do something now!’ • Insufficient funds • Constrained by UB work 33

  35. • Coeur d’Alene Basin Commission • State of Idaho, State of Washington • Coeur d’Alene Tribe, Spokane Tribe • Natural Resource Trustees • Restoration Partnership • Community leaders US Forest Service 34

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